Privacy Policy

We respect your privacy

Soup Life Coaching Pty Ltd ABN 19 103 772 185 trading as ‘Freedman’ and its associated entities (“Freedman”, “us”, “our”, “we”) recognizes the importance of protecting the personal information you provide us. Personal information is collected, used, disclosed and protected as set out in this Privacy Policy.

We adhere to the Australian Privacy Principles contained in the Privacy Act 1988 (Cth) (the Privacy Act) and to the extent applicable, the EU General Data Protection Regulation (GDPR)

By visiting our website(s) and entering into business or other dealings with us, you expressly consent to our collection, use and disclosure of your personal information in the manner set out in this Privacy Policy.

What is personal information?

When used in this Privacy Policy, the term ‘personal information’ has the meaning given to it in the Privacy Act. Generally, it is any information that can be used to personally identify you. For example, this may include your name, address, telephone number and email address. If the information we collect personally identifies you, or you are reasonably identifiable from it, the information will be considered personal information.

What personal information do we collect?

Freedman collects personal information in its provision of goods and services to you and in the operation and administration of its business activities. The personal information we collect may include:

Your contact information including your name, address, email addresses, telephone numbers;
Your financial information including your credit card and/or banking details;
your age, birthday, gender, and occupation or job title;
your usernames and passwords for interaction with Freedman and Freedman-related websites;
details of the products and services you have purchased from us or which you have enquired about, together with any additional information necessary to deliver those products and services and to respond to your enquiries;
personal information you provide to us through customer surveys or visits by our representatives from time to time; and
any additional information relating to you that you provide to us directly through our websites or indirectly through use of our websites or online presence, through our representatives, or otherwise.

When you come to our website (www.nickfreedman.com.au), we may collect certain information such as browser type, operating system, website visited immediately before coming to our site, etc.

How do we collect your personal information?

We collect personal information that you provide directly or indirectly:

over the phone, in person, via our websites and related social media platforms;
during conversations and/or any written communications between you and our representatives;
when you set up an account with us on our website;
when you register for any of our services; including blogs, alerts or other subscription services;
when you complete an order to purchase goods and services from us including completing a payment form or credit application;
when we engage you to provide us with any goods and services;
when you apply for a position with us or send us an expression of interest, directly or via a third party or recruiter; and
when you register to enter any competitions on our websites or social media platforms.

We may also collect personal information from third parties such as credit reporting agencies, law enforcement agencies and other government entities and from our network of partners and affiliates. Where we do, we protect this information as set out in this Privacy Policy.

Cookies

In some cases, we may also collect your personal information through the use of cookies and other tracking mechanisms. When you access our websites, we may send a ‘cookie’ to your computer. A ‘cookie’ is a small file temporarily stored on the hard disk of your computer by your browser. The information contained in the cookies may assist us with functions such as improved navigation and a high level of user friendliness and customization. It also enables us to keep track of products or services you view so that, if you consent, we can send you news about those products or services. We also use cookies to measure traffic patterns, to determine which areas of our websites have been visited and to measure transaction patterns in the aggregate. We use this to research our users’ habits to improve our online products and services. Our cookies do not collect personal information. The majority of web browsers automatically accepts cookies. If you do not wish to receive cookies, you can adjust your browser to disable cookies, but this may restrict your ability to access all or part of our websites. We may work with third party service providers who use the technologies described in this section and other tracking means to conduct analytics to help us track and understand how visitors use our website. For example, we may use a variety of third-party web analytics, including Google Analytics, to help us improve our website’s performance and user experiences.

What happens if we are unable to collect your personal information?

If you do not provide us with the personal information described above, some or all of the following may happen:

we may not be able to provide the products or services you requested, either to the same standard or at all, or assess any application you have made to us;
we may not be able to provide you with information about products or services that you may want, including information about discounts, sales, special promotions or competitions; or
we may be unable to customize the content of our websites to your preferences and your experience of our websites may not be as enjoyable or useful.

For what purposes do we collect, store, use and disclose your personal information?

We collect personal information about you for the primary purpose of providing you with a smooth, efficient and customized experience. In addition, we may collect, hold, use and disclose your personal information for the following related purposes:

providing products, services, deals and competitions offered by us and/or our commercial associates, partners and sponsors to you;
answering enquiries, fulfilling requests and providing information or advice about our business, existing and new products and services and for other customer service purposes;
resolving disputes, troubleshooting problems and enforcing our website Terms of Use (available on our website);
assessing the performance of our websites and improving the operation and functionality of those websites;
conducting business processing functions including providing personal information to our contractors, service providers, our related bodies corporate, or other third parties;
customizing website content, layout, and offerings on the websites and to improve our content and product offerings;
marketing (including direct marketing), planning, recruitment, product or service development, quality control and research purposes of Freedman and its contractors, service providers or other third parties;
administrative purposes including updating our records and keeping your contact details up to date;
processing and responding to any complaint made by you; and
complying with any law, rule, regulation, lawful and binding determination, decision or direction of a regulator, or in co-operation with any governmental authority of any country.

Your personal information will not be sold, rented, disclosed or shared other than as described in this Privacy Policy.

To whom may we disclose your personal information?

We may disclose and transfer your personal information for the purposes outlined above and related purposes:

to our related bodies corporate, employees, contractors, or third-party service providers located in Australia and overseas including without limitation, web hosting providers, IT systems administrators, mailing houses, couriers,
payment processors, data entry service providers, electronic network administrators, debt collectors, and professional advisors such as accountants, business advisors, lawyers and consultants;
to our agents and affiliates and related bodies corporate located in Australia and overseas;
to suppliers and other third parties with whom we have commercial relationships, for business, marketing and related purposes;
where you have consented; and
as required or authorized by law including to law enforcement, government or other organizations or where permitted under the Privacy Act.

If we do disclose your personal information to a third party, we will protect it in accordance with this privacy policy.

General Data Protection Regulation (GDPR) for the European Union (EU)

We will comply with the principles of data protection set out in the GDPR for the purpose of fairness, transparency and lawful data collection and use.
We process your personal information as a Processor and/or to the extent that we are a Controller as defined in the GDPR.
We must establish a lawful basis for processing your personal information. The legal basis for which we collect your personal information depends on the data that we collect and how we use it.
We will only collect your personal information with your express consent for a specific purpose and any data collected will be to the extent necessary and not excessive for its purpose. We will keep your data safe and secure.
We will also process your personal information if it is necessary for our legitimate interests, or to fulfil a contractual or legal obligation
We process your personal information if it is necessary to protect your life or in a medical situation, it is necessary to carry out a public function, a task of public interest or if the function has a clear basis in law.
We do not collect or process any personal information from you that is considered “Sensitive Personal Information” under the GDPR, such as personal information relating to your sexual orientation or ethnic origin unless we have obtained your explicit consent, or if it is being collected subject to and in accordance with the GDPR.
You must not provide us with your personal information if you are under the age of 16 without the consent of your parent or someone who has parental authority for you. We do not knowingly collect or process the personal information of children.

Your rights under the GDPR

If you are an individual residing in the EU, you have certain rights as to how your personal information is obtained and used. Freedman complies with your rights under the GDPR as to how your personal information is used and controlled if you are an individual residing in the EU.

Except as otherwise provided in the GDPR, you have the following rights:

(a) to be informed how your personal information is being used;

(b) access your personal information (we will provide you with a free copy of it);

(d) to delete your personal information (also known as “the right to be forgotten”);

(e) to restrict processing of your personal information;

(f) to retain and reuse your personal information for your own purposes;

(g) to object to your personal information being used; and

(h) to object against automated decision making and profiling.

Please contact us at any time to exercise your rights under the GDPR at the contact details in this Privacy Policy. We may ask you to verify your identity before acting on any of your requests.

Do we disclose your personal information to anyone outside Australia?

Information that we collect may from time to time be stored, processed in or transferred between parties or sites located in countries outside of Australia, including without limitation in the USA. Any data transfers between these countries will be protected by appropriate safeguards, these include one or more of the following: the use of standard data protection clauses adopted or approved by the European Commission which you can obtain from the European Commission Website; the use of binding corporate rules, a copy of which you can obtain from Freedman’s Privacy Officer (Nick Freedman – contact details below). You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Direct marketing

We may send you direct marketing communications and information about our existing or new products and services. These communications may be sent in various forms, including mail, SMS, fax and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). At any time, you may opt-out of receiving marketing communications from us by contacting us using the contact details below or by using the opt-out facilities provided in the marketing communications and we will then ensure that your name is removed from our mailing list. We do not provide your personal information to other organisations or third parties for the purposes of direct marketing.

Security

We are committed to ensuring that the information you provide to us is secure. In order to prevent unauthorized access, use or disclosure, we have put in place suitable and reasonable physical, electronic and managerial procedures to safeguard and secure information and protect it from misuse, loss, interference, unauthorized access, modification and disclosure.

Where we employ data processors to process personal information on our behalf, we only do so on the basis that such data processors comply with the requirements under the GDPR and that have adequate technical measures in place to protect personal information against unauthorised use, loss and theft. We may hold your information in either hard copy or electronic form. Personal information is destroyed or de-identified when no longer needed. As our websites are linked to the internet, and the internet is inherently insecure, we cannot provide any assurance regarding the security of transmission of information you communicate to us online. Accordingly, any personal information or other information which you transmit to us online is transmitted at your own risk. Although we take measures to safeguard against unauthorised disclosures of information, we cannot assure you that personal information that we collect will not be disclosed in a manner that is inconsistent with this Privacy Policy

Links

Our websites may contain links to other websites operated by third parties. These links are meant for your convenience only. Links to third party websites do not constitute sponsorship or endorsement or approval of these websites. We make no representations or warranties in relation to the privacy practices of any third party websites and we are not responsible for the privacy policies or the content of any third party websites. Third party websites are responsible for informing you about their own privacy practices. We encourage our users to be aware, when they leave our website, to read the privacy statements of each and every website that collects personal identifiable information.

Accessing and correcting your personal information

You may request details of personal information that we hold about you in accordance with the provisions of the Privacy Act, and to the extent applicable the EU GDPR. If you would like a copy of the information which we hold about you or believe that any information we hold on you is inaccurate, out of date, incomplete, irrelevant or misleading, then you may request we amend it by emailing us at connect@nickfreedman.com.au. We reserve the right to refuse to provide you with information that we hold about you, in certain circumstances set out in the Privacy Act or any other applicable law.

What is the process for complaining about a breach of privacy?

If you have any complaints about our privacy practices or believe that your privacy has been breached, please email connect@nickfreedman.com.au with a full description of the issue. We will treat your requests or complaints seriously and confidentially. A representative of Freedman will contact you within a reasonable time after receipt of your written complaint to discuss your concerns and outline options regarding how they may be resolved.

Contacting us

If you have any questions about this Privacy Policy, please contact us using the details below:

Attention: Nick Freedman

Post: 9 Powells Road, Brookvale, NSW 2100, Australia

Email: connect@nickfreedman.com.au

Changes to our Privacy Policy

We may modify this Privacy Policy from time to time.

This Privacy Policy was last updated October 2018

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